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Senate Bill Seeks to Raise Reporting Thresholds Under the Bank Secrecy Act

10/22/25

A new bill introduced in the U.S. Senate aims to significantly increase the dollar‑thresholds for two key reporting requirements under the Bank Secrecy Act (BSA). The proposed legislation would also require periodic inflation adjustments of the thresholds.

Under current law, financial institutions must file currency transaction reports (CTRs) and suspicious activity reports (SARs) when transactions exceed specified dollar amounts. The proposed measure—titled the “Streamline Act”—was introduced by Tim Scott (R‑S.C.), John Kennedy (R‑La.) and seven other senators. It targets two reporting triggers:

  • The CTR threshold would be raised from $10,000 to $30,000

  • Certain SAR thresholds would increase: one would go from $2,000 to $3,000, and another from $5,000 to $10,000

In addition to raising the numeric thresholds, the legislation would require the U.S. Department of the Treasury to adjust these amounts every five years to account for inflation.

The move reflects growing concern that current thresholds may be outdated. In some cases, critics say the low thresholds contribute to an excessive volume of low‑value reports, which may strain resources and obscure more serious illicit‑finance risks.

The legislation also comes at a time when banks and regulators are increasingly emphasising risk‑based approaches to financial‑crime compliance, focusing on higher‑impact activities rather than exhaustive reporting of low‑value transactions.

If passed, the Streamline Act would represent a meaningful shift in how banks approach compliance obligations under the BSA. Financial institutions may need to recalibrate internal monitoring systems, adjust policy thresholds, and communicate changes to affected customers and branches.

For banks, potential benefits include reduced burden from monitoring and filing large volumes of low‑value reports, and more capacity to focus on suspicious patterns and higher‑risk transactions. On the other hand, institutions will need to ensure that their risk‑assessment frameworks remain robust and continue to meet regulatory expectations.

The OBL will be watching how the bill progresses through the Senate and whether companion legislation emerges in the House of Representatives.